https://www.taxtmi.com/caselaws?id=296004 Section 263 revision is unavailable where the Assessing Officer has adopted one of two legally permissible views on the same facts and the revisional authority merely prefers another view. On the facts discussed, the assessee was treated as an agent of the State Government for development work, and that position had been accepted in earlier years and supported by precedent. The article notes that mere disagreement over the taxability of the income, including reliance on Article 289, did not by itself make the assessment order erroneous and prejudicial to the Revenue. The revisional order was therefore set aside. en-us Wed, 16 Oct 2019 00:00:00 +0530 Wed, 30 Jun 2021 08:19:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=296004 Section 263 revision is unavailable where the Assessing Officer has adopted one of two legally permissible views on the same facts and the revisional authority merely prefers another view. On the facts discussed, the assessee was treated as an agent of the State Government for development work, and that position had been accepted in earlier years and supported by precedent. The article notes that mere disagreement over the taxability of the income, including reliance on Article 289, did not by itself make the assessment order erroneous and prejudicial to the Revenue. The revisional order was therefore set aside. Case-Laws Income Tax Wed, 16 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=296004